High Value Council Tax Surcharge: Consultation
Dan Tomlinson Excerpts(4Â months, 1Â week ago)
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The Exchequer Secretary to the Treasury (Dan Tomlinson)
In the 2025 Budget, the Government announced the introduction of a new high-value council tax surcharge—HVCTS—on owners of the most valuable 1% of residential properties in England. Today, together with the Secretary of State for Housing, Communities and Local Government, I am launching a consultation on the detailed design of this new surcharge.
Households living in lower value homes often pay more council tax, relative to the value of their property, than those in the most expensive homes. For example, a Band D home in parts of the north can face a higher annual council tax bill than a property worth many millions of pounds in parts of central London. The HVCTS will change that, implementing a significant reform to improve fairness within England’s property tax system, ensuring that those with the most valuable properties pay their fair share.
From April 2028, owners of residential properties valued at ÂŁ2 million and above will be liable to pay the HVCTS, in addition to their existing council tax bill. Fewer than 1% of homes in England are expected to be affected. Properties will be valued for the purpose of the HVCTS and placed into one of four value bands, with fixed annual charges uprated in line with inflation. Council tax bands will remain separate to this new tax.
The consultation seeks views on the design of the tax including scope, support for those who cannot pay, how the tax will be administered and how owners can challenge and appeal their bill. The consultation also includes detailed information for local authorities, who will collect the tax on behalf of central Government. The revenue will be used to support funding for local government services. Local authorities will be fully compensated for any additional administrative burdens.
We welcome feedback on the detailed design set out in this consultation from local government, homeowners, tax experts, legal professionals and those in the property industry about the technical design and impact of the tax. The consultation will close on 14 July.
The consultation is available at:
https://www.gov.uk/government/consultations/high-value-council-tax-surcharge
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Oral Answers to Questions
Dan Tomlinson Excerpts(4Â months, 4Â weeks ago)
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Wendy Morton (Aldridge-Brownhills) (Con)
The Exchequer Secretary to the Treasury (Dan Tomlinson)
The Government have already taken action on fuel affordability at the pump. In last year’s Budget they extended the 5p per litre cap for a further five months, and they have also cancelled the increase that would have otherwise taken place in line with inflation at the start of this financial year.
Dave Doogan
If you were a gardener with a Renault Trafic or a builder with a Ford Ranger in Scotland, Mr Speaker, you would be paying over ÂŁ150 just to fill up at the pump in order to get to work. When Spain and Poland and Germany and France and Italy and Ireland and Australia are all intervening to help their industry and economy, our Chancellor here stands idly by and congratulates herself on the quality of her inaction. We do not want to hear from Anas Sarwar in Scotland, because he promised ÂŁ300 off our energy bills and they are now ÂŁ700 higher than the level that he promised in 2024. We want to hear from the Chancellor. What is she going to do about diesel specifically, and when is she going to do it, to keep the grafters of Scotland turning up for work?
Dan Tomlinson
The Scottish National party has had ample opportunity in Scotland to invest in energy, to invest in energy infrastructure and to invest in the changes that we need in our economy to bring down energy bills, and when it comes to fuel duty—[Interruption.]
Dan Tomlinson
When it comes to fuel duty, it is of course worth noting that it is lower today, in cash terms, than it has been in any year since 2009.
Mr Mohindra
If the increase in fuel prices rather than the Chancellor’s two disastrous Budgets is to blame for the stagnating economy, why does the Chancellor believe that raising fuel duty further in September will help to reduce the cost of living when in fact it will harm the economy more, and will deliver another direct hit to the pockets of my constituents?
Dan Tomlinson
Before the conflict in Iran started we saw inflation falling, we saw unemployment falling and we saw growth increasing by 0.5% in one month at the start of the year. That showed that our economic plan was the right plan for this country, and it is important that we stick to it rather than returning to the bad old days of the high borrowing and high interest rates that the Conservatives brought us when they had a chance to run the economy.
Wendy Morton
Labour is at war with motorists, and Reform’s idea of protesting about fuel prices was revealed at their non-event yesterday—and, indeed, its members are not even here today. Only we on the Conservative Benches are standing up for our motorists and our constituents. Will the Chancellor take this opportunity to help our constituents, our businesses and our motorists, and adopt our plan to extend fuel duty relief—yes or no?
Dan Tomlinson
I agree with the right hon. Member that Reform’s rabble yesterday was deeply underwhelming. As for fuel duty, the rate is currently lower than it was at any point under the last Government, or, at least, it was never lower under the last Government than it is now. In real terms, it is lower than it has been at any point since 1993.
Bill Esterson (Sefton Central) (Lab)
The fuel duty freeze is of course very welcome for drivers of petrol and diesel vehicles, but this is the second time in just over four years that petrol and diesel prices have gone through the roof as a result of international oil and gas uncertainty. Is it not time that we gave as much support as possible to those who want to make the transition to electric vehicles? According to Autotrader, the average price of electric vehicles is already lower than that of petrol and diesel vehicles. Will the Government confirm that they are bringing forward plans for greater ability to charge at home and bringing down the cost of electricity as far and as fast as possible, so that more drivers can benefit from long-term lower driving costs?
Dan Tomlinson
My hon. Friend is right to say that we are seeing a continued uptake of electric vehicles—we saw that in March this year. More electric vehicles were purchased in March than in any month in British history, and we can see that take-up is continuing to increase. This Government are increasing and expanding the grants for those who want to buy an electric vehicle, and we are making progress on permitted development rights, so that those who do not have easy access to charging in their driveways can have easy and cheap access to on-street charging.
Gerald Jones (Merthyr Tydfil and Aberdare) (Lab)
Even before the current conflict in the middle east, fuel suppliers in the Merthyr Tydfil part of my constituency were charging an average of 10p per litre more than those in other parts of my constituency and neighbouring towns. Even London fuel prices were cheaper than they were in Merthyr Tydfil, and the situation has not improved since. I have written to suppliers and met some, with limited success, and I have asked the Competition and Markets Authority to look at the matter, which it has so far not done. May I ask the Chancellor to offer whatever assistance she can and to urge fuel providers in Merthyr Tydfil to act fairly? Will she urge the CMA to consider what it can do to ensure fair play for my constituents?
Dan Tomlinson
I thank my hon. Friend for his representations, and for the work that he is undertaking on behalf of his constituents in a rural part of our country. We are making sure that all garages are on the new fuel finder website that the Chancellor has introduced. That should drive up competition and make it easier for the people he represents to compare the cost at the pumps in different garages nearby. It is good to hear that he has been in touch with the CMA; the Chancellor, too, has been in discussion with it about making sure that we have competition in this industry. If I can help him to get a meeting with the CMA, I will happily assist.
James Wild (North West Norfolk) (Con)
Whereas the Conservatives froze fuel duty for 14 years, Labour is planning to increase it by 5p, costing families ÂŁ150 a year and hauliers ÂŁ2,000. When the Chancellor was asked to reverse her hike, she said she was
“loath to spend Government money”
to do so. There is no such thing as Government money; there is only taxpayers’ money. Rather than increase taxes again, will she actually help households and businesses facing higher prices and scrap this fuel hike?
Dan Tomlinson
We on the Labour Benches are fiscally responsible. We will make sure that we continue to get borrowing down in a sustainable way, as we did over the last financial year, when borrowing fell by ÂŁ20 billion. Whenever the Conservatives have had the chance, they have borrowed more, which pushes up interest rates for families and means that we have to have higher taxes in the long run. That is not the approach that we will take. The plans that the Conservatives set out in their final Budget before they left office would have seen fuel duty increase every single year. Instead, we have frozen it since we took over.
Leigh Ingham (Stafford) (Lab)
Peter Fortune (Bromley and Biggin Hill) (Con)
The Exchequer Secretary to the Treasury (Dan Tomlinson)
The reforms to business property relief maintain significant relief for owners of business assets. That is beyond what is available to others and is more generous than at any time under Margaret Thatcher, for example, when the rate of relief was a maximum of 50% on all business assets, including the first ÂŁ2.5 million. I do not think that Conservative Members would argue that we did not see growth in the private sector while Thatcher was in power.
Peter Fortune
I agree with the Minister, of course, that Margaret Thatcher really was the sunny uplands of this country.
Small and medium-sized enterprises provide the backbone for our economy in Bromley and Biggin Hill. Many of those businesses are still family owned, suffering from the slew of taxation from this Labour Government. Family Business UK’s analysis, published just last month, said that 57% of businesses are still suffering from the business property relief that, despite the slight U-turn that the Minister alluded to, is still impacting their business. Does the Minister agree that the best way to growth is to support small businesses and not to tax them out of existence?
Dan Tomlinson
I am glad that the hon. Gentleman acknowledges that while Margaret Thatcher was in power she was taxing such businesses through business property relief more than this Labour Government. We have a fair and balanced approach when it comes to making sure that we can raise revenues from the very largest businesses, including agricultural businesses, so that we can sustainably support the reduction in borrowing that this Government are bringing about.
Perran Moon (Camborne and Redruth) (Lab)
Hundreds of small family businesses across Cornwall will soon be subject to a significant increase in their property costs as a result of the Valuation Office Agency’s decision to reclassify serviced offices, business centres and co-working spaces. Will the Chancellor arrange for me to meet Treasury officials and the VOA to discuss how the impacts of that reclassification may be mitigated?
Dan Tomlinson
I thank my hon. Friend for his question. I am aware of the issue that he raises; I have met representatives of the sector in recent weeks to discuss it. It follows changes to case law over recent years, but it is of course an important issue that affects many businesses. I would be happy to meet my hon. Friend to discuss it.
Iqbal Mohamed (Dewsbury and Batley) (Ind)
Bradley Thomas (Bromsgrove) (Con)
The Exchequer Secretary to the Treasury (Dan Tomlinson)
The Government have introduced a support package worth ÂŁ4.3 billion to protect rate payers across the country against the impact of the independently set new property values, whereby properties have been valued for the first time since the pandemic. We have also introduced permanently lower multipliers for eligible retail, hospitality and leisure properties worth nearly ÂŁ1 billion a year, and this will benefit more than 750,000 high street businesses.
Bradley Thomas
I recently met Chris, the owner of Chapters Hair in Bromsgrove, who told me that current conditions are the most difficult he has faced in 25 years of trading, which he attributes directly to the decisions taken by the Chancellor. Why is it that the Chancellor of the Exchequer and the Government across the board are riding roughshod over what business owners think—the people who know best how to run their businesses—and when will the Government get off their backs and get on their side?
Dan Tomlinson
Under the previous Government, the business rates multiplier—the tax rate—paid by medium-sized businesses and the very largest businesses was exactly the same. We have implemented significant reforms to the way businesses rates work so that the system supports the high street, and the tax rate paid by small high street businesses will now be 33% lower than the rate paid by the largest properties, such as online giants. Of course, the revaluation since the pandemic has had an effect, and that is why we have stepped in to provide support.
Richard Fuller (North Bedfordshire) (Con)
This month, a comprehensive survey by UKHospitality showed that one in seven of our hotels, pubs and restaurants will close as a direct result of the Chancellor’s policies. Many of those businesses represent the hopes and dreams, hard work and savings of the people who set them up. Therefore, as I am permitted, rather than having the Minister come to the Dispatch Box, may I ask the Chancellor to come to the Dispatch Box to answer this? If it was not me standing here but one of those people who had founded a business and is now going through the gut-wrenching process of closing it because of her policies, what would she say to them?
Dan Tomlinson
Of course, the Government want to do all we can to support businesses up and down the country—small, medium and large. That is why we are working hard to put the economic stagnation we had over the last 14 years behind us. We are seeing economic growth rising—growing by 0.5% in February; we saw unemployment falling; and we were seeing Government borrowing falling as well. Those are the long-term changes we need to lay the foundations so that businesses can grow, invest and hire more people. It is disappointing that the Conservatives seem to have forgotten what we need to provide stability in our economy.
Cat Smith (Lancaster and Wyre) (Lab)
Daisy Cooper (St Albans) (LD)
Business rates bills have been landing on doormats over the last few weeks, and some small businesses in St Albans and beyond tell me that the future looks bleak, with some taking the crushing decision to close their doors. Will the Chancellor please look again at the eye-watering revaluations and release the full 20p discount for small businesses, which the Government legislated to do, to save our high streets?
The Exchequer Secretary to the Treasury (Dan Tomlinson)
On business rates, the hon. Member will know that this Government inherited the plans that were set in train for an independent revaluation of properties to take place for the first time since the pandemic. It would not have been the right thing to do to delay that independent revaluation for those businesses who have seen their rates fall since the pandemic, so we went ahead with it, and we then put in £4.3 billion of support to limit the increases in bills that businesses would pay. Of course we keep all taxes under review, but we have for the first time put in a differential within the business rates system so that high street businesses face a lower tax rate—a lower multiplier—than the largest online giants.
Antonia Bance (Tipton and Wednesbury) (Lab)
Mr Speaker
Order. This is topical questions, and I want to get other colleagues in, please.
Dan Tomlinson
I am always happy to take questions on business rates, even months after the decision set out at the Budget, and I thank the hon. Member for reading out the Labour manifesto. We have made significant changes to business rates by introducing the new lower multiplier for high street businesses so that they can pay a lower tax rate than the largest online giants.
Chris Bloore (Redditch) (Lab)
Draft Vaping Duty Stamps (Requirements, Reviews and Appeals) Regulations 2026
Dan Tomlinson Excerpts(4Â months, 4Â weeks ago)
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The Exchequer Secretary to the Treasury (Dan Tomlinson)
I beg to move,
That the Committee has considered the draft Vaping Duty Stamps (Requirements, Reviews and Appeals) Regulations 2026.
It is a pleasure to serve under your chairship, Ms Vaz. The draft regulations make provision for when vaping products must and must not bear a duty stamp, and ensure that decisions made in relation to United Kingdom representatives are subject to rights of review and appeal. They do so by setting out the stamping requirements that will apply under the vaping duty stamps scheme, and by amending the Finance Act 1994 so that relevant decisions fall within the existing review and appeal framework. The draft regulations provide part of the detailed framework needed for the administration, control and enforcement of vaping products duty and the vaping duty stamps scheme.
At the 2024 Budget, the Chancellor confirmed the structure and rate of vaping products duty; the new duty will be charged at a flat rate of £2.20 per 10 ml on all vaping liquid from 1 October 2026. Vaping duty stamps are the primary compliance mechanism for the new tax, requiring every duty-paid vaping product to carry a highly secure, scannable label. These stamps provide a visible and traceable confirmation that duty has been paid, enabling His Majesty’s Revenue and Customs and other agencies to assess compliance, and strengthening enforcement in a market with high risks of illicit activity. They also give retailers and consumers confidence that the products they are purchasing are legitimate.
Let me summarise the three measures in the draft regulations. First, they set out when vaping products must bear a duty stamp. Under the draft regulations, vaping products produced or imported on or after 1 October 2026 must be stamped at or before the point at which they pass an excise duty point. Products produced or imported before 1 October 2026 must be stamped by 1 April 2027.
Secondly, the draft regulations set out where the duty stamp requirement does not apply. They apply exceptions for products possessed by a private individual for that individual’s own use; products to be exported from the United Kingdom; products to be shipped or carried on a ship, aircraft or train as stores; products to be used in an export shop; and products that are afforded relief from excise duty.
Thirdly, the draft regulations provide for reviews and appeals in relation to United Kingdom representatives in the vaping duty stamps scheme. They achieve this by amending the Finance Act 1994, so that decisions relating to UK representatives fall within the existing statutory review and appeal framework. This means that decisions made by HMRC in relation to such representatives—those acting on behalf of overseas businesses for duty stamps purposes—can be reviewed and, where appropriate, appealed in an independent tribunal. This is an important safeguard, as the vaping duty stamps scheme expressly provides a role for UK representatives where overseas manufacturers wish to supply to the UK market.
I hope that members of the Committee will join me in supporting the draft regulations.
Dan Tomlinson
I thank the Opposition spokesmen for their questions and continued scrutiny of this important new measure that the Government are introducing to support our vaping products duty.
I am satisfied that the timelines are appropriate: registration opened on 1 April, giving businesses six months to apply. As I mentioned, products imported to the UK before 1 October this year will have a longer period before they are subject to enforcement.
There is always a risk that increases in rates of taxation will change consumers’ behaviour.
Vicky Foxcroft (Lewisham North) (Lab)
I declare an interest: I have not smoked for more than a decade, and I vape. Does the Minister agree that we have to be careful that the language we use does not discourage people from changing from smoking to vaping? Vaping has been shown to be successful in getting many people to stop smoking. The health benefits are there. None of us wants young people to vape, but vaping is successful in getting long-term smokers to move off smoking.
Dan Tomlinson
My hon. Friend makes an important point. The emergence of vapes in recent years has provided people up and down the country with a route away from smoking. That is to be welcomed. At the same time, the chief medical officer is right to highlight the risks and health impacts associated with vaping, although they may be lower than the impact of smoking cigarettes.
Vicky Foxcroft
The Minister says they may be lower. I believe it is said that they are significantly lower.
Dan Tomlinson
I am not an expert on the differences in the health impacts, and I trust my hon. Friend’s expertise and experience in this space. However, the chief medical officer is clear that there are still health impacts, and he supports the changes we have made. It is worth highlighting that, although the vaping products duty will be introduced at the rate of £2.20 per 10 ml, we are increasing the duty on cigarettes so that the tax differential is maintained. I thank my hon. Friend for her interventions and the insight she has brought to today’s debate.
On enforcement, HMRC is in the process of recruiting more than 300 new compliance officers. As the shadow Exchequer Secretary mentioned, ÂŁ10 million of additional funding will be made available for Border Force. We are confident that the cost of implementing this measure will be outweighed many times over by the benefits to the Exchequer of the additional revenue it brings in. Unlike the one-off set-up costs, that additional revenue is there for the long term,. The vaping products duty will bring in ÂŁ565 million by 2030.
The shadow Exchequer Secretary is always right to mention the need for timely and up-to-date guidance, and I will press officials to make sure we get the guidance out as soon as we can if more clarity is required. When it comes to individual procurement decisions, I am aware of the case he mentioned. HMRC assures me that it followed robust and proper processes in that case, as it does in all procurement. The bids underwent thorough evaluation and assurance process, and we follow strict procurement rules when awarding contracts, ensuring value for money for taxpayers. As for the subject of HMRC enforcement action, we will make sure to enforce against the appropriate person or business in each relevant case.
Question put and agreed to.
Oil and Gas Decommissioning Relief Deeds
Dan Tomlinson Excerpts(5Â months ago)
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The Exchequer Secretary to the Treasury (Dan Tomlinson)
The Government’s fiscal approach for oil and gas aims to balance supporting investment and growth with ensuring a fair return for the nation in exchange for the use of its resources.
At Budget 2013, the Government announced they would begin signing decommissioning relief deeds. These deeds represented a new contractual approach to provide oil and gas companies with certainty on the level of tax relief they will receive on future decommissioning costs.
Since October 2013, the Government have entered into 110 decommissioning relief deeds. Offshore Energies UK estimates that these deeds have so far unlocked approximately ÂŁ13.5 billion of capital, which can now be invested elsewhere.
The Government committed to report to Parliament annually on progress with the decommissioning relief deeds. The report for financial year 2024-25 is provided below.
Number of decommissioning relief agreements entered into: the Government entered into one decommissioning relief agreement in 2024-25.
Total number of decommissioning relief agreements in force at the end of the 2024-25 financial year: 109 decommissioning relief agreements were in force at the end of the financial year. We have entered into one more agreement since the end of the 2024-25 financial year, but this is out of scope of the report.
Number of payments made under any decommissioning relief agreements during that year, and the amount of each payment: five payments were made under a decommissioning relief agreement in 2024-25, for ÂŁ9.55 million in total. These were made in relation to the provisions recognised by HM Treasury from 2015 onwards as a result of companies defaulting on their decommissioning obligations.
Total number of payments that have been made under any decommissioning relief agreements as at the end of that year, and the total amount of those payments: 24 payments have been made under any decommissioning relief agreement as at the end of the 2024-25 financial year, totalling around ÂŁ355 million.
Estimate of the maximum amount liable to be paid under any decommissioning relief agreements: the Government have not made any changes to the tax regime that would generate a liability to be paid under any decommissioning relief agreements. HM Treasury’s 2025-26 accounts will recognise a provision currently estimated to be £133 million in respect of decommissioning expenditure incurred as a result of companies defaulting on their decommissioning obligations [1]. The majority of this is currently expected to be realised over the next five years.
[1] This figure which is an estimate at the last interim reporting period is unaudited and takes into account payments made subsequent to the financial year covered by this written ministerial statement. The estimate is under review and subject to audit ahead of the year end reporting period and may be updated to reflect newer information or changes required by accounting standards.
[HCWS1534]
Stamp Duty Land Tax: Periodic Tenancies
Dan Tomlinson Excerpts(5Â months ago)
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The Exchequer Secretary to the Treasury (Dan Tomlinson)
Tenant wellbeing is central to the Government’s recent Renters’ Rights Act 2025, which will deliver on our manifesto commitment to transform the experience of private renting and give renters much greater security and stability so that they can stay in their homes for longer.
The Act will improve the current system for both the 11 million private renters and the 2.3 million landlords in England. It will give renters much greater security and stability so that they can stay in their homes for longer, build lives in their communities, and avoid the risk of homelessness.
The Government are today setting out our intention to ensure that no one is newly brought into stamp duty land tax as a result of the changes in the Renters’ Rights Act.
Although most people understand how SDLT applies when related to the change of ownership of a property, it is also charged on some rents when their net present value exceeds ÂŁ125,000. In practice, the vast majority of private tenants do not reach the SDLT threshold of ÂŁ125,000 and so do not pay SDLT on their rent. This is because assured shorthold tenancies, which make up the majority of private tenancies, are likely to renew regularly, so the net present value of the rent is calculated over a relatively short duration.
From 1 May 2026, the Renters’ Rights Act will abolish fixed-term assured shorthold tenancies. Instead, all tenancies will be periodic, with tenants able to stay in their home until they decide to end the tenancy by giving two months’ notice. This will end the injustice of tenants being trapped paying rent for substandard properties and offer more flexibility to both parties to respond to changing circumstances.
Following this change, the net present value of rent under a continuing lease will be calculated assuming a lease that continues indefinitely. This means the net present value of the rent could increase and exceed the ÂŁ125,000 threshold at which SDLT becomes payable, even though the underlying tenancy arrangements have not substantively changed.
The Government intend to legislate in the 2026-27 Finance Bill so that any residential lease that will be considered an assured tenancy under the Housing Act 1988, as amended by the Renters’ Rights Act, will not give rise to a SDLT charge on the rent element. The Government will set out the detail of this legislation at or before this year’s Budget.
The legislation will apply retrospectively from the date on which existing tenancies become section 4A assured tenancies—as defined in section 146 of the Renters’ Rights Act), which is expected to be on 1 May 2026.
HM Revenue and Customs will not collect any SDLT on the rent element of an assured tenancy from that date until the date the legislation takes overriding effect.
This measure ensures that tenants and landlords are not adversely affected by technical interactions between the Renters Rights Act and SDLT legislation, and reflects the Government’s commitment to the smooth and fair implementation of reforms to the private rented sector.
[HCWS1535]
Draft Major Sporting Events (Income Tax Exemption) (Glasgow 2026 Commonwealth Games) Regulations 2026
Dan Tomlinson Excerpts(5Â months ago)
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The Exchequer Secretary to the Treasury (Dan Tomlinson)
I beg to move,
That the Committee has considered the draft Major Sporting Events (Income Tax Exemption) (Glasgow 2026 Commonwealth Games) Regulations 2026.
It is a pleasure to appear before you today, Sir Alec. The draft regulations provide an income tax exemption for non-UK resident competitors, officials and certain other designated individuals employed by or associated with the participating national teams and international federations, or otherwise involved with the Glasgow 2026 Commonwealth games.
The Government recognise the great benefits that all sport—including sport at the highest level—brings to this country. International tournaments inspire the next generation of athletes, bring together communities and boost the economy. I am sure that members of the Committee will be aware of the Government’s commitment to making the UK an attractive location to host world-class sporting events.
Successive Governments have provided income tax exemptions for hosting major sporting events, such as the 2022 Birmingham Commonwealth games, the 2023 Women’s Finalissima, the 2024 UEFA champions league final and the 2024 world athletics indoor championships. I should point out that tax exemptions of this type are reserved for only the most exceptional events. I am hopeful—indeed, confident—that the Committee will agree that this event meets that criterion.
The exemption covers income directly related to participating in the Glasgow 2026 Commonwealth games as well as income arising in relation to services and duties performed specifically for the event. Being exposed to taxes in two countries is administratively complex and consideration would also have to be given to matters such as withholding taxes, completing self-assessment tax returns and the relevant double taxation treaties.
The income tax exemptions for the Glasgow 2026 Commonwealth games further support the Government’s commitment to make the UK a global destination for world-class sport. I commend the regulations to the Committee.
Dan Tomlinson
I thank all Members for their contributions and questions. It is fantastic that the city of my hon. Friend the Member for Glasgow East will host the Commonwealth games again. They were a great success for the country and for countries throughout the Commonwealth last time they were held in that great city. I know that it has had some difficult times lately with the fire at Glasgow Central station. I hope that this summer, we can all enjoy the best that Glasgow has to offer, including the sporting events in Glasgow East.
I thank the shadow Exchequer Secretary for reminding the Committee that he stands up as a thinking man’s Al Carns.
Dan Tomlinson
I spent four weeks deliberating on whether to put out that video and I deeply regret the decision to do so.
As ever, the shadow Exchequer Secretary asked important and pertinent questions. He asked why the dates do not align with those of the games. That is because many athletes will not be here for those precise dates. Those involved with the sporting teams or with the relevant accreditation may come here in the previous days and weeks. The dates have been set in the usual way; it is typical practice.
On the hon. Gentleman’s first question about accreditation, the Department for Culture, Media and Sport will work closely with the Commonwealth games on that, as they have done for previous sporting events, to ensure that the right people are accredited. He also asked whether HMRC will ensure that income is treated and taxed correctly and appropriately. I give the previous Government credit for making progress on closing the tax gap. We are glad to continue with that. The tax gap has fallen this year and is set to fall further over the rest of the Parliament. We will of course keep a weather eye on the activities of those coming here.
The hon. Member for Torbay asked an important question about what else the Government are doing to support the Commonwealth games. Last June, we pledged to spend at least ÂŁ400 million on grassroots facilities over the next four years to support those who live in close proximity to the games. I hope that those who are considering competing will not just think about whether they have to pay tax in two countries or the double taxation treaties, but will find an inducement in participating and celebrating their skills, training and hard work. Perhaps the joy of a medal will also be an inducement.
Again, I thank Members for their contributions and commend the regulations to the Committee.
Question put and agreed to
Electricity Generator Levy
Dan Tomlinson Excerpts(5Â months ago)
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The Exchequer Secretary to the Treasury (Dan Tomlinson)
The electricity generator levy was introduced in 2023 and is a temporary tax on windfall revenues for large renewables. The EGL is currently calculated as 45% of a generator’s annual revenue above a benchmark price, which is currently £82.61 per MWh and has been increased in line with the consumer prices index since 2024. New investments in renewable energy are not subject to the EGL.
When gas prices are high, renewable generators that are not in receipt of contracts for difference receive substantial increases in revenue because they can sell the electricity they generate at higher prices, without having any new costs.
The Government have reviewed the design of the EGL in light of the conflict in the middle east and are announcing today that the 45% EGL rate will increase to 55% and will be extended past its scheduled conclusion in 2028. This will support the Government’s objective of reducing the impact of gas prices on businesses and households. Firstly, it will encourage participation at a competitive price in wholesale contracts for difference, a new proposal announced today by the Secretary of State for Energy Security and Net Zero, my right hon. Friend the Member for Doncaster North (Ed Miliband), which seeks to weaken the link between high gas prices and high electricity generation prices. Secondly, it will ensure a proportion of any exceptional revenues resulting from the pass-through of high gas prices to electricity generators’ revenues is available to Government to support businesses and households with the impacts of the conflict in the middle east on the cost of living.
The rate increase will take effect from 1 July 2026 to respond to the high prices that generators are benefiting from now because of the crisis in the middle east.
[HCWS1528]
Carbon Price Support
Dan Tomlinson Excerpts(5Â months, 1Â week ago)
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The Exchequer Secretary to the Treasury (Dan Tomlinson)
I am today confirming to the House that carbon price support will be removed from April 2028.
CPS is a tax on fossil fuels used in electricity generation, introduced in 2013 by a previous Government to strengthen the carbon price for electricity generation above the price provided by the emissions trading scheme.
CPS has done its job and is no longer fit for purpose. Coal has been driven off the grid and the ETS has matured, with a tighter cap to drive the signal for electricity generators to decarbonise, so now is the right time to simplify the tax and carbon pricing system.
With our clean power 2030 mission, we are already reducing our electricity system’s reliance on volatile fossil fuels and we no longer need this additional tax to provide incentives in the system to decarbonise our grid.
CPS removal will also help to offset costs to all bill payers of the British industrial competitiveness scheme, and this will reduce electricity bills for manufacturing sectors in the industrial strategy.
The Government will legislate for the removal of CPS in a future Finance Bill.
[HCWS1519]
Finance (No. 2) Bill
Dan Tomlinson ExcerptsWednesday 11th March 2026
(6Â months, 2Â weeks ago)
Commons ChamberRead Full debate Finance Act 2026 View all Finance Act 2026 Debates Read Hansard Text Watch Debate Read Debate Ministerial Extracts Amendment Paper: Report Stage Amendments as at 11 March 2026 - (11 Mar 2026)
The Exchequer Secretary to the Treasury (Dan Tomlinson)
I beg to move, That the clause be read a Second time.
Madam Deputy Speaker (Judith Cummins)
With this it will be convenient to discuss the following:
Government new clause 6—Offshore income gains: savings.
Government new clause 7—Pensions: abolition of the lifetime allowance charge.
New clause 1—Report on fairness and scope of the loan charge settlement opportunity—
“(1) HM Revenue and Customs must, within 12 months of the passing of this Act, lay before the House of Commons a report on the operation and impact of any loan charge settlement opportunity established under section 25 of this Act.
(2) The report under subsection (1) must in particular consider—
(a) whether the terms of the settlement opportunity are available to individuals who have previously settled or fully paid liabilities arising from disguised remuneration loan arrangements,
(b) whether the terms of the settlement opportunity are available to individuals with disguised remuneration loan arrangements falling outside the loan charge years specified in Part 7A of the Income Tax (Earnings and Pensions) Act 2003,
(c) the extent to which any differences in treatment between these groups and those eligible for the settlement opportunity affect perceptions of fairness, and
(d) the potential impact of such perceptions on future tax compliance and trust in the tax system.
(3) The report must include—
(a) an assessment of whether extending more favourable settlement terms to the groups described in subsection (2)(a) and (b) would improve fairness and consistency, and
(b) any recommendations HMRC consider appropriate in light of that assessment.”
This new clause would require HMRC to report on the operation and fairness of the new loan charge settlement opportunity. It would consider whether more favourable terms are, or should be, available to those who have a already settled or fully paid liabilities, and to those with arrangements outside the loan charge years.
New clause 2—Report on implementation customer service standards in relation to sections 253 to 258—
“(1) The Commissioners must, within six months of the commencement of sections 253 to 258, lay before the House of Commons a report setting out—
(a) customer service standards for persons granted exemptions under regulations made under paragraph 14 or 15 of Schedule A1 to the Taxes Management Act 1970, including—
(i) maximum waiting times for telephone helpline calls,
(ii) minimum call answering rates,
(iii) maximum response times for written correspondence, and
(iv) availability of in-person support;
(b) measures taken to ensure adequate staffing and resources to meet those standards;
(c) data on actual performance against those standards in each quarter; and
(d) remedial action to be taken where standards are not met.
(2) The customer service standards published under subsection (1) must ensure that persons granted exemptions under regulations made under paragraph 14 or 15 of Schedule A1 to the Taxes Management Act 1970 can access support through non-digital channels with service levels comparable to those historically provided before the introduction of Making Tax Digital.
(3) The Commissioners must publish an annual report on compliance with the customer service standards established under subsection (1), and lay a copy of the report before the House of Commons.”
This new clause would require HMRC to establish and publish customer service standards for tax payers exempted from Making Tax Digital requirements due to digital exclusion.
New clause 3—Report on winter fuel payment charge and related compliance and collection measures—
“(1) The Commissioners for HM Revenue and Customs must lay before the House of Commons a report on the operation and effects of the charge applied to winter fuel payments where an individual’s income exceeds the relevant threshold, including the compliance and collection arrangements introduced under section 55 and Schedule 10 in relation to that charge.
(2) The report under subsection (1) must in particular consider—
(a) the effect of the charge on people whose income exceeds the threshold by a small amount, and any resulting behavioural impacts,
(b) the administrative complexity and proportionality of introducing a tapered abatement for winter fuel payments,
(c) the potential effect of updating section 7 of the Taxes Management Act 1970 so that a winter fuel payment charge becomes a notifiable liability for tax assessment purposes, including the operation of penalties for failure to notify, and the interaction with existing exceptions for liabilities reflected in PAYE tax coding adjustments or where a taxpayer has already been issued a notice to file a self-assessment return, and
(d) the operation and effectiveness of any new PAYE regulation provisions that allow winter fuel payment charges to be collected via tax code adjustments in year, and which allow HMRC to repay any overpaid income tax related to the charge via the tax code within the same year.”
This new clause would require HMRC to report to Parliament on the operation of the winter fuel payment charge, including its effect on people whose income exceeds the threshold by a small amount. The report would also cover the implications of updating section 7 of the Taxes Management Act 1970 to make winter fuel payment charge liabilities notifiable for tax assessment purposes.
New clause 4—Implementing the prohibition of the promotion of certain tax avoidance arrangements—
“(1) The Treasury must, within six months of the passing of this Act, consult and report on—
(a) how to ensure the regulations specified under section 156(2) of this Act can address the potential for harm to individuals and small businesses from the promotion online and via social media of tax avoidance arrangements by professionals and by social media tax influencers,
(b) the potential for detriment to individuals who are liable for tax arising from such promotions, and
(c) what steps HMRC should take to inform the public of the risks posed by online tax avoidance arrangements.
(2) The Chancellor of the Exchequer must lay before Parliament a report on the outcome of the consultation under subsection (1), including the steps they plan to take to address any issues identified.
(3) In this section, “tax influencer” means an individual who—
(a) is not a tax professional,
(b) promotes, markets or otherwise encourages participation in a tax avoidance arrangement, and
(c) does so by means of a social media service, where that promotion is carried out—
(i) in the course of a business or trade, or
(ii) in consideration of, or in expectation of, any payment or other benefit, whether from a promoter of the arrangement or from the social media service, or
(iii) with the intention of increasing engagement with, or the monetisation of, content relating to the arrangement.”
New clause 8—Impact of section 84 (General betting duty charge on remote bets)—
“The Chancellor of the Exchequer must, before 1 April 2027, lay before the House of Commons an impact assessment on the potential effects of the implementation of section 84 of this Act on the size of the illegal betting market.”
This new clause would require the Chancellor of the Exchequer to undertake an impact assessment on the potential effects of implementation of section 84 on the illegal betting market.
New clause 9—Impact of changes to gambling duties on the economy of Gibraltar—
“The Chancellor of the Exchequer must, before 1 April 2027, lay before the House of Commons an impact assessment on the potential effects of the implementation of sections 83 and 84 of this Act on the economy of Gibraltar.”
This new clause would require the Chancellor of the Exchequer to undertake an impact assessment on the potential effects of implementation of sections 83 and 84 on the economy of Gibraltar.
New clause 10—Review of operation of the carbon border adjustment mechanism—
“(1) The Treasury must, each calendar year for five years following the passing of this Act, undertake a review of the operation of—
(a) Part 5, and
(b) Schedules 16 to 19.
(2) A review undertaken under subsection (1) must be conducted in accordance with sections 28 to 32 of the Small Business, Enterprise and Employment Act 2015.
(3) A review undertaken under subsection (1) must be completed as soon as reasonably practicable after the calendar year to which it relates.
(4) The Treasury must lay before Parliament a copy of each review carried out under this section as soon as reasonably practicable following the completion of the review.”
This new clause would place a duty on the Chancellor to conduct a post-implementation review of the operation of the carbon border adjustment mechanism one year after the implementation of the UK CBAM and every subsequent year.
New clause 11—Uprating of allowance amounts for agricultural property—
“The Chancellor of the Exchequer must, within six months of the passing of this Act, undertake and publish an assessment of the potential merits of uprating annually the relief allowance amount for agricultural property by the change in the value of agricultural land.”
New clause 12—Review of anti-forestalling provisions relating to Agricultural Property Relief—
“(1) The Treasury must conduct a review of the effects of the anti-forestalling provisions relating to Agricultural Property Relief.
(2) The review must, in particular, consider the effects of those provisions on—
(a) succession planning and intergenerational transfer of agricultural land and businesses,
(b) the viability and continuity of family-run farms,
(c) food security and domestic agricultural production,
(d) land management, environmental stewardship, and the condition of the countryside, and
(e) the availability of agricultural land for active farming.
(3) In conducting the review, the Treasury must consult such persons as it considers appropriate, including representatives of the agricultural sector.
(4) The Treasury must lay before the House of Commons a copy of the report within 12 months of the coming into force of the anti-forestalling provisions under this Act.”
New clause 13—Review of impact of Act on complexity of the tax system and administrative burdens—
“(1) The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before Parliament a report setting out the impact of the measures contained within this Act on the complexity of the tax system and the costs of tax administration.
(2) The report under subsection (1) must identify the measures in this Act which—
(a) add to the complexity of the tax system;
(b) reduce the complexity of the tax system;
(c) increase the number of individuals, businesses or other organisations liable for tax or for tax reporting;
(d) reduce the number of individuals, businesses or other organisations liable for tax or for tax reporting;
(e) increase the resources required for HM Revenue and Customs to administer the tax system and ensure compliance; and
(f) reduce the resources required for HM Revenue and Customs to administer the tax system and ensure compliance.
(3) The report must include an assessment of the impact of this Act on the complexity of the tax system, and on the time and cost of tax administration and compliance, for each of the following groups—
(a) pensioners;
(b) taxpayers on low incomes;
(c) personal taxpayers as a whole;
(d) self-employed people;
(e) microbusinesses;
(f) small and medium-sized businesses;
(g) large businesses;
(h) personal representatives who administer a person’s estate after their death;
(i) professional tax advisers; and
(j) HM Revenue and Customs.”
This new clause would require the Chancellor to conduct an assessment of the impact of the Act on the complexity of the tax system and on the time and cost of tax administration for taxpayers and their representatives, and for HMRC.
New clause 14—Review of impact on unemployment and youth employment—
“(1) The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before Parliament a report reviewing the impact of the provisions of this Act on levels of unemployment in the UK.
(2) The report under subsection (1) must, in particular, assess—
(a) the impact of the provisions of this Act on overall unemployment levels;
(b) the impact on employment levels for persons aged 16 to 24;
(c) the impact on rates of economic inactivity among young people;
(d) the effect on youth participation in apprenticeships, training, and entry-level employment;
(e) regional variations in youth unemployment arising from the provisions of this Act; and
(f) the impact on sectors with high levels of youth employment, including hospitality, retail, and the creative industries.
(3) The report must include an assessment of—
(a) the extent to which changes made by this Act have affected hiring decisions by small and medium-sized enterprises;
(b) any disproportionate impact on disadvantaged young people, including those from low-income households or with disabilities; and
(c) projected impacts over a three-year period following the passing of this Act.
(4) The Chancellor of the Exchequer must, following publication of the report under subsection (1), make a statement setting out what steps, if any, the Government proposes to take in response to its findings.”
This new clause requires the Chancellor to review and report on the impact of the Act on unemployment, with particular regard to young people aged 16 to 24.
New clause 15—Notification of taxpayers affected by frozen thresholds—
“(1) HM Revenue and Customs must take reasonable steps to identify individuals who, as a result of—
(a) the freezing of the starting rate limit for savings under section 9 of this Act, or
(b) the freezing of the personal allowance or the basic rate limit under section 10 of this Act, will—
(i) become liable to income tax for the first time, or
(ii) become liable to income tax at a higher rate than in the previous tax year.
(2) HM Revenue and Customs must ensure that each individual identified under subsection (1) is provided with a written notification before the start of the relevant tax year.
(3) A notification under subsection (2) must—
(a) explain that the individual’s tax liability is affected by the freezing of income tax thresholds,
(b) state whether the individual will pay income tax for the first time or move into a higher tax band, and
(c) provide information on where the individual can obtain further guidance about their tax position.
(4) HM Revenue and Customs must publish, no later than six months after the end of each affected tax year, a report setting out—
(a) the number of individuals notified under this section,
(b) the number of individuals who became income taxpayers for the first time as a result of sections 9 and 10, and
(c) the number of individuals who moved into a higher tax band as a result of those sections.
(5) In this section “written notification” includes electronic communication.”
This new clause would require HM Revenue and Customs to notify individuals who, as a result of the freezing of income tax thresholds in the Act, will pay income tax for the first time or move into a higher tax band.
New clause 16—Review of the impact of tax changes on household finances—
“(1) The Chancellor of the Exchequer must, within six months of this Act being passed, publish an assessment of the impact of changes introduced by sections 9,10 and 69 on household finances.
(2) The assessment must evaluate how households across different income levels are affected by these changes.”
This new clause requires the Chancellor of the Exchequer to assess and publish a report on how the freezing of tax thresholds to 2030-31 impacts households at various income levels.
New clause 17—Report on impact of sections 9, 10 and 69—
“Within three months of this Act being passed, the Chancellor of the Exchequer must lay before the House of Commons a report setting out—
(a) the number of taxpayers who will pay income tax at each rate during each tax year between 2026-27 and 2030-31 under sections 9, 10 and 69,
(b) the number of those taxpayers who are pensioners or are of State Pension Age,
(c) comparative figures for each tax year since 2020-21,
(d) comparative projected figures for each tax year to 2034-35, and
(e) comparative figures with a scenario under which normal uprating policy had been implemented for financial years 2020-21 through 2030-31.”
This new clause requires the Chancellor of the Exchequer to assess how many people will be in each income tax bracket from 2026-27 through to 2030-31, together with comparative figures before and after that period.
New clause 18—Review of the effect of sections 63 to 68—
“(1) HM Treasury must carry out a review of the effect of sections 63 to 68 of this Act (Pension interests).
(2) The review under subsection (1) must include an assessment of—
(a) the impact of those sections on individuals’ pension savings and beneficiaries, including on estate values and inheritance tax liabilities,
(b) the administrative effects on personal representatives, pension scheme administrators, and HM Revenue and Customs, and
(c) any behavioural effects on how pensions are used during life and on death.
(3) HM Treasury must lay before the House of Commons a report setting out the findings of the review under subsection (1) no later than six months after the date on which sections 63 to 68 come into force.”
This new clause would require HM Treasury to review and report on the effects of Clauses 63 to 68 of the Bill, which introduce inheritance tax charges on unused pension funds and death benefits, including their impacts on individuals, administrators, and behaviour, and to publish the findings to Parliament.
New clause 19—Administration of inherited pension pots—
“(1) HM Revenue and Customs must review the tax administration arrangements relating to inherited pension pots.
(2) The purpose of the review under subsection (1) is to ensure that—
(a) inheritance tax and related tax checks do not cause unreasonable delays in the payment of pension death benefits to beneficiaries, and
(b) bereaved families are able to receive pension benefits within a reasonable period following a member’s death.
(3) In carrying out the review, HM Revenue and Customs must have regard to—
(a) the cumulative administrative burden placed on personal representatives, pension scheme administrators, and beneficiaries,
(b) the interaction between inheritance tax reporting, clearance processes, and pension scheme payment rules, and
(c) any evidence of prolonged delays in the payment of inherited pension benefits.
(4) HM Revenue and Customs must publish the outcome of the review, including any proposed changes to its processes or guidance, within 12 months of the passing of this Act.”
This new clause would require the Government to address delays in the payment of inherited pension pots by reviewing HMRC’s tax administration processes, with the aim of preventing prolonged waiting periods for bereaved families.
New clause 20—Review of cumulative impact on the hospitality sector—
“(1) The Chancellor of the Exchequer must, within six months of the passing of this Act, lay before the House of Commons a report assessing the cumulative impact on the hospitality sector of—
(a) the measures contained in section 86 of this Act, and
(b) changes to taxation and business costs affecting that sector introduced outside this Act since 2020.
(2) For the purposes of subsection (1)(b), changes to taxation and business costs include, but are not limited to—
(a) changes to employer National Insurance contribution rates or thresholds,
(b) changes to business rates, including reliefs and revaluations, and
(c) any other fiscal measures which materially affect operating costs for hospitality businesses.
(3) A report under subsection (1) must include an assessment of the impact of the matters listed in that subsection on—
(a) levels of employment across the United Kingdom within the hospitality sector,
(b) the number of hospitality businesses ceasing to trade,
(c) the number of new hospitality businesses established, and
(d) the financial sustainability of hospitality businesses.
(4) In this section, “the hospitality sector” means persons or businesses operating in the provision of food, drink, accommodation, or related services.”
This new clause would require the Chancellor of the Exchequer to assess and report on the cumulative impact on the hospitality sector of alcohol duty measures in the Act alongside wider fiscal changes, including employer National Insurance contributions and business rates.
Amendment 1, page 2, line 7, leave out clause 4.
This amendment removes the increase in dividend rates from the Bill.
Amendment 2, page 2, line 16, leave out clause 5.
This amendment removes the new savings rates of income tax from the Bill.
Amendment 3, page 2, line 21, leave out clause 6.
This amendment removes the new rates of income tax on property income from the Bill.
Amendment 4, page 4, line 31, leave out clause 7.
This amendment removes the property rates of income tax for 2027-28 from the Bill.
Amendment 5, page 5, line 20, leave out clause 10.
This amendment removes the freeze in income tax thresholds from the Bill.
Amendment 112, in clause 13, page 6, line 13, leave out from “means—” to “fifteenth” on line 16.
Amendment 113, page 6, line 20, leave out from “(1)” to end of line 23 and insert
“for “£3 million” substitute “£6 million””.
Amendment 114, page 6, line 27, leave out subsection (3)(d).
Amendment 115, page 7, line 1, leave out from “(1)” to end of line 4 and insert
“for “£30 million” substitute “£120 million””.
Amendment 116, page 7, line 5, leave out from “(2)” to end of line 13 and insert
“for “£30 million” substitute “£120 million””.
Amendment 117, page 7, line 10, leave out from “(1)” to end of line 13 and insert “for “250” substitute “500””.
Amendment 118, page 7, line 14, leave out from “(2)” to end of line 15 and insert “for “250” substitute “500””.
Amendment 119, page 7, line 25, leave out from “15 years” to end of line 27.
Amendment 120, page 7, line 28, leave out subsection (7).
Amendment 121, page 8, line 28, leave out sub-paragraph (4).
Amendment 122, in clause 14, page 8, line 36, leave out from “(5A))” to “, and” in line 38 and insert “, £20 million”.
Amendment 123, page 8, line 40, leave out from “company” to end of line 1 on page 9, and insert “, £10 million.”
Amendment 124, page 9, line 5, leave out from “section 252A)” to “, and” in line 7, and insert “, £40 million”.
Amendment 125, page 9, line 10, leave out from “company” to end of line 11 and insert “, £24 million.”
Amendment 126, page 9, line 15, leave out from “section 252A)” to “, and” in line 17 and insert “, £40 million”.
Amendment 127, page 9, line 19, leave out from “company” to end of line 21 and insert “, £24 million.”
Amendment 128, page 9, line 24, leave out sub-paragraph (b).
Amendment 129, page 9, line 38, leave out “that is not a specified Northern Ireland company”.
Amendment 130, page 10, line 4, leave out “that is not a specified Northern Ireland company”.
Amendment 131, page 10, line 10, leave out leave out subsections (6) and (7) and insert—
“(6) In section 186 (the gross assets requirement)—
(a) in subsection (1)(a) for “£15 million” substitute “£30 million”
(b) in subsection (1)(b) for “£16 million” substitute “£35 million”
(c) in subsection (2)(a) for “£15 million” substitute “£30 million”
(d) in subsection (2)(b) for “£16 million” substitute “£35 million””
Amendment 132, in clause 15, page 10, line 30, leave out from “(6A))” to “, and” in line 32 and insert “, £20 million”.
Amendment 133, page 10, line 34, leave out from “company” to end of line 36 and insert “, £10 million.”
Amendment 134, page 11, line 4, leave out from “section 331A)” to “, and” in line 6 and insert “, £40 million”.
Amendment 135, page 11, line 8, leave out from “company” to end of line 10 and insert “, £24 million.”
Amendment 136, page 11, line 14, leave out from “section 331A)” to “, and” in line 16 and insert “, £40 million;”.
Amendment 137, page 11, line 18, leave out from “company” to end of line 20 and insert “, £24 million.”
Amendment 138, page 11, line 23, leave out subsection (6)(b).
Amendment 139, page 11, line 34, leave out leave out subsections (7) and (8) and insert—
“(6) In section 297 (the gross assets requirement)—
(a) in subsection (1)(a) for “£15 million” substitute “£30 million”
(b) in subsection (1)(b) for “£16 million” substitute “£35 million”
(c) in subsection (2)(a) for “£15 million” substitute “£30 million”
(d) in subsection (2)(b) for “£16 million” substitute “£35 million””.
Government amendments 12 to 14.
Amendment 6, page 78, line 4, leave out clause 62.
This amendment removes the changes to the thresholds for Agricultural Property Relief and Business Property Relief from the Bill.
Amendment 7, page 78, line 11, leave out clause 63.
This amendment removes the imposition of inheritance tax on pension interest.
Government amendments 15 to 47.
Amendment 9, in clause 74, page 91, line 25, at end insert—
“(7) The Treasury must make regulations under subsection (1) within 60 days of the passing of this Act.
(8) Before making regulations under subsection (1), the Treasury must consult—
(a) organisations representing infected and affected individuals,
(b) the Infected Blood Compensation Authority, and
(c) bereaved families of victims who have died awaiting compensation.
(9) The regulations made under subsection (1) must make provision for identifying and assisting the estates of deceased victims in claiming inheritance tax relief, including—
(a) outreach to known affected families,
(b) assistance with evidence gathering where medical records have been destroyed,
(c) clear and accessible guidance in plain language, and
(d) a dedicated helpline staffed by trained caseworkers familiar with the infected blood scandal.
(10) The Treasury must, within 6 months of regulations under this section coming into force, and every 6 months thereafter, lay before Parliament a report on—
(a) the number of victims who have died since the previous report while awaiting compensation,
(b) the number of estates that have received inheritance tax relief,
(c) the average time taken to process claims for relief,
(d) any identified barriers preventing families from accessing their entitlement, and
(e) steps taken to expedite outstanding infected blood compensation claims.”
This amendment requires the Chancellor of Exchequer to make regulations under this section within 60 days of Royal Assent. It requires mandatory consultation with those directly affected, and a support service to help bereaved families navigate the system. It also places a six-monthly reporting requirement on the Government.
Amendment 10, page 94, line 4, leave out clause 77.
This amendment would maintain the existing zero-rating for the purposes of VAT on the full value of the lease of a vehicle to a disabled person supplied through the Motability Scheme.
Amendment 11, page 96, line 6, leave out clause 78.
This amendment would maintain insurance premium tax relief for all vehicles let to a disabled person and supplied through the Motability Scheme.
Amendment 101, page 103, line 29, leave out clause 86.
Government amendments 48 to 53.
Government amendments 56 to 61.
Amendment 8, page 442, line 2, leave out schedule 12.
This amendment would remove the changes to Agricultural Property Relief and Business Property Relief from the Bill.
Amendment 109, in schedule 12, page 442, line 20, leave out from “and” to end of line 23 and insert—
“(c) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),”.
This amendment would maintain 100% business relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.
Amendment 110, page 442, line 29, leave out from “and” to end of line 32 and insert—
“(c) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% trust relief allowance available in relation to that occasion (see sections 124G to 124K),”.
This amendment would maintain 100% business relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.
Amendment 111, page 443, line 9, leave out from “and” to end of line 12 and insert—
“(b) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),”.
This amendment would apply 100% agricultural property trust relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.
Amendment 89, page 444, line 16, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 102, page 444, line 16, after “£2.5 million” insert
“plus
(aa) the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”.
This amendment, and Amendments 103 to 107, would allow landlords to access 100% relief from inheritance tax where they have let land or farms to tenant farmers on secure agreements under the Agricultural Holdings Act 1986 or on agreements under the Agricultural Tenancies Act 1995 for 10 years or more.
Amendment 90, page 449, line 36, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 103, page 449, line 36, after “£2.5 million” insert
“plus
(aa) the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”.
See Amendment 102.
Amendment 91, page 450, line 25, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 104, page 450, line 25, after “£2.5 million” insert
“plus the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995”.
See Amendment 102.
Amendment 67, page 450, line 27, leave out “30 October 2024” and insert “1 March 2027”.
This amendment, along with Amendments 68 to 87 would remove the transition period in respect of the changes to agricultural property and business property relief and delay the implementation date so that the changes would take effect for transfers made after 1 March 2027.
Amendment 95, page 450, line 27, leave out “30 October 2024” and insert “6 April 2026”.
This amendment, with Amendments 96 to 100, would remove the transition period in respect of the changes to agricultural property and business property relief so that the changes take effect for transfers made from 6 April 2026.
Amendment 68, page 451, line 6, leave out “30 October 2024” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 96, page 451, line 6, leave out “30 October 2024” and insert “6 April 2026”.
See explanatory statement for Amendment 95.
Amendment 92, page 451, line 22, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 105, page 451, line 22, after “£2.5 million” insert
“plus
(aa) the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”.
See Amendment 102.
Amendment 93, page 453, line 15, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 106, page 453, line 15, after “£2.5 million” insert
“plus the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995”.
See Amendment 102.
Amendment 94, page 453, line 17, after “£2.5 million” insert
“excluding the value of any joint interest in an agricultural or business tenancy that was made in a transaction at arm’s length between persons not connected with each other or that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.”
Amendment 107, page 453, line 17, after “£2.5 million” insert
“plus the value of any agricultural property subject to a tenancy under the Agricultural Holdings Act 1986, or a tenancy with a fixed term of 10 years or more without unconditional break clauses available to the landlord under the Agricultural Tenancies Act 1995,”.
See Amendment 102.
Amendment 69, page 453, line 23, leave out “30 October 2024” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 97, page 453, line 23, leave out “30 October 2024” and insert “6 April 2026”.
See explanatory statement for Amendment 95.
Amendment 108, page 454, line 40, at end insert
“(But see subsection (2A).)
(2A) If the Treasury estimates that the value of agricultural land has increased by more than the percentage increase in the consumer prices index during the same period, then it must instead make an order by statutory instrument amending each relief allowance amount relating to agricultural property by the percentage increase in the value of agricultural land.”
Government amendments 54 and 55.
Government amendments 62 to 64.
Amendment 88, page 458, line 31, at end insert—
“(1A) In Section 227, leave out subsection (3)(a) and insert—
“(a) if the chargeable transfer was made on death and to the extent that it qualified for relief under Chapters I or II of part V of this Act, eighteen months after the end of the month in which the death occurred, or
(b) if the chargeable transfer was made on death and to the extent that it did not qualify for relief under Chapters I or II of part V of this Act, six months after the end of the month in which the death occurred, and””
This amendment would defer the period for the payment of inheritance tax on assets qualifying for payment by instalments by 12 additional months.
Amendment 70, page 460, line 8, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 71, page 460, line 9, leave out sub-paragraphs (2) and (3).
See explanatory statement for Amendment 67.
Amendment 98, page 460, line 9, leave out sub-paragraphs (2) to (4).
See explanatory statement for Amendment 95.
Government amendments 65 and 66.
Amendment 72, page 460, line 23, leave out “sub-paragraph (3) will not apply” and insert
“the transfer will prove to be an exempt transfer”.
See explanatory statement for Amendment 67.
Amendment 73, page 460, line 27, leave out from “paragraph” to end of paragraph 17(5)(b) and insert
“comes into force on 1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 99, page 460, line 27, leave out from “paragraph” to end of paragraph 17(5)(b) and insert
“comes into force on 6 April 2026”.
See explanatory statement for Amendment 95.
Amendment 74, page 460, line 34, leave out “30 October 2024” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 100, page 460, line 34, leave out “30 October 2024” and insert “6 April 2026”.
See explanatory statement for Amendment 95.
Amendment 75, page 460, line 37, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 76, page 460, line 39, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 77, page 460, line 41, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 78, page 461, line 2, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 79, page 461, line 9, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 80, page 461, line 14, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 81, page 461, line 22, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 82, page 461, line 26, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 83, page 461, line 37, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 84, page 461, line 42, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 85, page 463, line 19, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 86, page 463, line 26, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Amendment 87, page 463, line 32, leave out “6 April 2026” and insert “1 March 2027”.
See explanatory statement for Amendment 67.
Dan Tomlinson
I am glad to return to the Commons to debate the Finance Bill on Report. Although I am sure that it would have been of interest to Members on both sides of the House, I am also glad that we have not just had a set of two 45-minute debates on the Ways and Means motions. The opportunity was there, but I am glad that Members did not take it in full. We now have ample time for this important Report stage.
I thank Members on both sides of the House for their contributions in Committee. I thank in particular the shadow Exchequer Secretary to the Treasury, the hon. Member for North West Norfolk (James Wild), for his scrutiny and challenge, and for the invitation to his wonderful constituency, which I hope to take up one day. As yet, no other Opposition Front Bencher has offered me such an enticing prospect as a visit to their constituency, but I look forward to those invitations.
Before I turn to individual amendments, I wish to reflect briefly on the Budget that was delivered in November by my right hon. Friend the Chancellor of the Exchequer. That Budget took fair and necessary decisions to deliver on the Government’s promise of change, to support cuts in the cost of living, to enable NHS waiting lists to continue falling, and to ensure that our national debt fell as a share of GDP and that borrowing falls over the course of this Parliament. As the Chancellor said in this place yesterday and on Monday, Government borrowing—public sector net borrowing—has fallen from 5.2% to 4.3% of GDP, which is a fall of 1 percentage point. That is very significant and means that our borrowing is coming down, as part of our plan to bring stability back to the public finances.
Sir Ashley Fox (Bridgwater) (Con)
Does the Minister acknowledge that debt reduction is taking place only because the Government have increased taxes by ÂŁ66 billion? That contrasts with the tax rise of ÂŁ7 billion that the Labour party promised in its manifesto. Could he explain the huge discrepancy between that manifesto promise and what the Government are imposing on our constituents?
Dan Tomlinson
I ask the hon. Member to consider whether his party wishes to identify ÂŁ66 billion of expenditure cuts or borrow ÂŁ66 billion more. I do not think that either option is what the British public want; they want us to bring borrowing down and get public finances under control, after they were spun out of control by Liz Truss and the previous Government. The public understand the need for fair and responsible increases in taxation to ensure that we can invest in our public services and in the future of our country.
Chris Vince (Harlow) (Lab/Co-op)
On taxation, does the Minister agree that this Labour Government’s decisions have meant increased spending on the NHS? A number of my Harlow constituents are self-employed, and the really long waits in A&E and for hospital operations were having a huge impact on their businesses and on their household finances.
Dan Tomlinson
I strongly agree with my hon. Friend. I thank him for making his representations again and for his ability to mention Harlow in his interventions. It is a fantastic part of the country, not too far from my constituency in north London, and I know just how strongly he seeks to represent it and to make sure that the public services in his patch—the local hospitals and schools—get the investment they need. That is why he and I are able to proudly support this Government’s decisions to bring the public finances back into good order, as well as to invest in our public services and to get borrowing down.
Of course, though, since the Budget, and particularly in recent days, the world has changed. As the Chancellor set out last week in responding to the Office for Budget Responsibility’s spring forecast, it is more important than ever that the Government continue to deliver on our economic plan. The choices that we have made at previous Budgets will fix long-standing issues in the taxation system, restore economic and fiscal stability, and lay the economic foundations that we need for higher growth and higher living standards across our fantastic country.
The Bill legislates to deliver on those choices, all while sticking to our commitment not to raise the main rates of income tax, employee national insurance contributions or VAT. We are also providing stability for businesses by keeping to important commitments in our corporate tax road map to keep our corporation tax rate at 25%—the lowest in the G7—rather than having it chop and change up and down, like it did during previous Administrations.
I thank all those who have submitted written evidence throughout the Bill’s passage. Following concerns raised by professional bodies and concerns discussed in the Public Bill Committee, I would like to take this opportunity to reiterate my reassurances to the sector that measures that directly impact tax advisers are intended to create a fairer tax advice market. I have heard concerns that tax advisers might be penalised if they file a client’s tax return late when their client has not provided their approval for filing the return on time. I want to clarify that these powers are not designed to penalise responsible tax advisers who act in good faith, and in that specific scenario, a tax adviser would not be penalised under His Majesty’s Revenue and Customs’ stronger powers. The Government are committed to ensuring that the tax system works effectively for everyone, which is why we are introducing a number of amendments on Report to ensure that the tax system is working effectively and as intended.
I turn to the first group of Government amendments. New clause 5 removes specific provisions that could prevent offshore income gains from being designated under the temporary repatriation facility, or TRF, to ensure that they can be designated as intended. The amendments also simplify the existing treatment of offshore non-reporting funds held by offshore structures for all taxpayers. New clause 6 introduces transitional provisions for offshore income gains arising before 6 April 2025.
Following the abolition of the lifetime allowance, new clause 7, as we were just discussing, ensures that multiple different regimes do not apply, providing clarity for pension schemes and members. It ensures that any necessary regulations can have a retrospective effect back to 6 April 2024, clarifies the scope of the original power, extends the power by a further three months and ensures that regulations are subject to the affirmative parliamentary procedure.
The Government are making a number of minor and technical amendments to help provide greater clarity and address important points that have been raised by stakeholders, particularly during the passage of the Bill. These amendments simply put the original legislative intent beyond doubt.
Amendments 12 and 13 ensure that clause 23 will apply only to general earnings for the tax year 2026-27 and subsequent tax years that are paid on or after 6 April 2026. Amendment 14 tightens the existing provisions under clause 24 to ensure that those rules do not catch legitimate agency structures.
Amendments 48 and 51 remove legislation that is not necessary under clause 43 and ensure that the TRF legislation works as intended, so that beneficiaries from overseas trusts are able to make designations in connection with offshore income gains.
Amendments 49, 50 and 52 are consequential amendments to schedule 3 and clause 43. They remove references to omitted legislation and insert wording to clarify reference to the Taxation of Chargeable Gains Act 1992.
Amendment 53 to clause 49 makes clear that a person concluding contracts on behalf of a non-resident company must be present in the UK when concluding those contracts in order to create a permanent establishment in the UK.
Amendments 56 to 61 to schedule 11 concern the rules preventing fund managers from circumventing the revised carried interest tax regime. These amendments ensure that the provision operates as intended, where two connected persons work in the same business, with each connected person only taxed on their own carried interest.
Sir Ashley Fox
It sounds as if the Minister is adding many, many extra pages to our tax code. What provisions will he be bringing forward to shorten and simplify the tax code?
Dan Tomlinson
The hon. Gentleman raises an important point. We need to do all that we can to ensure that we are simplifying our tax code in order to make it easier for tax advisers, individuals and businesses. I have also asked that question, but I am reassured by my officials—I am sure that the hon. Member could consult Hansard too—that this is a typical number of amendments to be made to a Finance Bill. This is a long Finance Bill, but there are a whole range of important changes that the Government wish to introduce and to make progress on. I am sure Members from all parties have enjoyed poring over the changes to the tax legislation. I do take his point about simplification, though; it is something that I wish to focus on. If hon. Members have good ideas in that space, they would genuinely be welcome to write to me.
Mr Joshua Reynolds (Maidenhead) (LD)
On the simplification of our tax system, I do not see in the Government amendments any changes to the loan charge system, as we proposed in Committee, meaning that people who have already settled their loan charge will be excluded from the changes being introduced. Does the Minister agree that one consequence of this might be that when something like this comes up in the future, people will not want to settle with the Government because they will think that a better deal will be coming up? Would it not be a simpler tax system to say that we could retrospectively apply some of these changes?
Dan Tomlinson
I thank the hon. Gentleman for his intervention and for his engagement in the Public Bill Committee. The loan charge is an important issue. I focused on it after receipt of Ray McCann’s independent review into the loan charge, which was commissioned by my predecessor. The scope of that review and the decisions made by the Government are such that only those who are directly affected by the loan charge will have the opportunity to take up the new settlement that was recommended by McCann, to which the Government have added a £5,000 further deduction. The Government’s position was that, because the loan charge was an exceptional decision made by the previous Government, it was right that the changes proposed by McCann would apply only to that group. There will be those who engaged in the use of disguised remuneration schemes from before 2010, and with them, as with all taxpayers, this Government are very clear that individuals do have a responsibility to pay their tax.
Amendments 54 and 55, and 62 to 66, are minor amendments to the definitions of business property qualifying for relief. They ensure that the replacement property provisions relating to reorganisation or amalgamation of unquoted shares reflect the new legislation, and that unquoted securities, such as loan notes, continue to qualify for relief only where they are part of a controlling interest in a company.
Amendments 15 to 47 to clauses 63 to 67 make a series of minor technical changes to ensure that the provisions on inheritance tax and pensions operate as intended. These ensure that excluded and exempt benefits are not subject to inheritance tax, nor to the new withholding and payment notices.
I am sure that Members from all parts of the House have enjoyed that run-through of those minor and technical amendments. I can provide them with the good news that that run-through has now concluded. I sincerely hope and expect that the proposed amendments will ensure that the legislation that was set out, and that has been discussed and scrutinised, works as intended, and that HMRC—the organisation that I am proud to be the Minister with responsibility for—has the powers to responsibly collect tax and revenue, which funds the vital public services on which our country relies.
I therefore commend new clauses 5, 6 and 7 and Government amendments 12 to 66 to the House, and I look forward to hon. Members’ contributions.
Dan Tomlinson
I thank all Members for their contributions at this stage of the Bill’s passage—we are almost there. I will take some time to respond directly to the amendments that have been discussed today.
I will first address amendments 1 to 4, 5 and 7, which were spoken to by the shadow Exchequer Secretary, the hon. Member for North West Norfolk (James Wild). Amendments 1 to 4 would remove the increase in dividend, savings and property income tax rates; amendment 5 would prevent income tax thresholds from staying at their current levels until 2030; and amendment 7 would remove reforms to the inheritance tax treatment of pensions. Based on costings that have been certified by the OBR, the direct impact of these amendments would cumulatively reduce forecast revenue raised in 2029-30—the year of relevance for our fiscal rules—by a whopping £12 billion. These amendments therefore pose a significant risk to the sustainability of our public finances and to our ability to fund the NHS and the public services that we all rely on. I therefore urge the House to reject them.
Sir Ashley Fox
Would the Minister concede that if that was offset by ÂŁ12 billion less welfare spending, there would not be any threat to the sustainability of the finances?
Dan Tomlinson
If the Conservatives had credible plans and a credible history of reining in welfare spending, then I would, of course, be interested in taking them seriously. However, it was the shadow Chancellor, the right hon. Member for Central Devon (Sir Mel Stride), who was the Work and Pensions Secretary when the welfare budget exploded. We are now trying to get on top of that.
I will not address new clauses 15 to 19 directly. The Government have set out our position on them at previous stages, although I do urge the House to reject them today.
I will now turn to the points raised by the hon. and learned Member for North Antrim (Jim Allister) around amendments 112 to 139, which would have the effect of removing the distinction between the options available in respect of “specified Northern Ireland companies” and other companies from clauses 13, 14 and 15. The hon. and learned Gentleman has made his views known very clearly both today and on Second Reading. I will make the same point that the Economic Secretary to the Treasury made on Second Reading: as he will be aware—although he did not, I believe, mention this in his speech —service companies are able to benefit from the increase in the threshold. It is the Government’s understanding that there are very few, if any, goods and electricity companies in Northern Ireland that are close to the current enterprise management incentive limits, and we therefore think there will be minimal impact from these companies being subject to the previous scheme limits.
Jim Allister
Is the Minister saying to the House that the criterion here is to look at each region and see who is near the thresholds, and then to magically increase those that are? Surely the truth is that the Minister is not increasing the threshold because he has handed the power to do so to a foreign jurisdiction.
Dan Tomlinson
I am just stating a fact, which is that there are few—if any—businesses near the relevant thresholds. The hon. and learned Member made the point that the Government’s decision may be hampering growth and investment; I do not think that is the case. I am proud to be a member of a Government who are seeking to deepen and strengthen our ties with the European Union so that we in this country can increase our productivity through better flowing trade, working together with our partners. I therefore urge the House to reject amendments 112 to 139.
Amendments 6 and 8 relate to the changes to business property relief and agricultural property relief as raised by the shadow Exchequer Secretary as well as the hon. Members for Weald of Kent (Katie Lam) and for Keighley and Ilkley (Robbie Moore). If we were to adopt those amendments, we would weaken the public purse by about ÂŁ300 million a year. It would also leave a status quo that contributes to the very largest estates paying lower average effective inheritance tax rates than the smallest estates. I therefore urge the House to reject those amendments.
The hon. Member for Keighley and Ilkley asked for clarity on payment deadlines in the inheritance tax system. The Government’s position is that the six-month point is the right one. It has applied for a long time, and it is not our position to change that timeline when these changes come into force.
Robbie Moore
I note that that is the Government’s position, but what level of assessment have they done of the negative implications of having just a six-month period as opposed to extending that to 18 months? From the engagement that Opposition Members have had with many stakeholders, we have found that the consequences are huge. What assessments have the Government done in relation to this specific issue?
Dan Tomlinson
I am sure this issue was considered before the policy was announced, and I have considered it too since I have been in post. It is worth pointing out that HMRC already offers several payment options to help personal representatives pay inheritance tax. That allows banks, building societies or investment providers to pay some or all the inheritance tax due from the deceased person’s accounts before probate is granted. There are a range of ways available to people to enable them to pay IHT within six months. I therefore urge the House to reject amendment 88.
Dan Tomlinson
The president of the National Farmers Union mentioned in his speech to the farmers’ conference just a few weeks ago that he was glad of my engagement with farmers—he personally called out that engagement. I took a trip to the constituency of my hon. Friend the Member for Hexham (Joe Morris), after being invited there by him, and I was glad to meet farmers there and learn about their experiences.
Amendments 89 to 94 seek to exclude the value of any joint interest in certain agricultural business tenancies from the ÂŁ2.5 million allowance for 100% relief. It is worth pointing out that the drafting of the amendments risks those tenancies falling outside the allowance entirely so that, rather than providing 100% relief, the Government are concerned that the drafting would mean that the relief might well be capped at 50% for those with joint tenancies. That is certainly a reason to reject those amendments.
Dan Tomlinson
If the right hon. Member will forgive me, I will make progress, having spoken for eight minutes already.
Amendments 102 to 107 would mean that unlimited 100% agricultural property relief would be available on agricultural land rented out for at least 10 years. The Government’s position is that the House should reject these amendments.
The hon. Member for Witney (Charlie Maynard) also spoke to new clause 11. The Government have decided on a range of thresholds that will continue to be frozen until the end of the decade. We have made the decision across the piece, as was mentioned earlier, to sustainably and fairly raise revenue to fund our public services and get borrowing down. I therefore urge the House to reject amendments 102 to 107. I will not address in detail new clause 12 or amendments 67 to 87, 95 to 100 and 108 to 111, as the Government have set out their position on those amendments at previous stages, and I urge the House to reject them.
My hon. Friends the Members for Stoke-on-Trent Central (Gareth Snell), and for Halesowen (Alex Ballinger), both made important contributions on the amendments relating to gambling duty. I have twice met the Minister from Gibraltar mentioned by my hon. Friend the Member for Stoke-on-Trent Central and have been in correspondence with him. I understand that there are significant impacts on the economy in Gibraltar, and I hope to keep engaging on and discussing that.
Gareth Snell
I am glad about the Minister’s meetings, but while he is at the Dispatch Box, will he give an assurance that there are no future surprises and no significant tax-change announcements planned that will disproportionately affect areas such as Gibraltar as a result of their dependence on certain industries?
Dan Tomlinson
We will, of course, continue to engage with Ministers in Gibraltar. It would not be appropriate for me to write future Budgets at this Dispatch Box today, but we have made a significant change when it comes to gambling taxation. Rather than make further changes, the Government will monitor the impact of that change. I also thank my hon. Friend the Member for Halesowen for his contributions and representations.
The hon. Member for Aberdeen North (Kirsty Blackman) made a helpful speech— with not much notice, I understand. She raised the matter of alcohol duty. It is worth pointing out that the uprating in alcohol duty just keeps the revenue in line with inflation. We have seen reductions in alcohol consumption, driven not by the tax staying in line with inflation, but changes in consumers’ consumption habits. I therefore urge the House to reject amendment 101 and new clause 20.
Graham Stuart
The Minister has overcome his natural reluctance, and I am grateful to him. A lot of people get confused about the BPR tax changes. If there was ÂŁ10 million in a company that someone inherited, and it was subject to those changes, the claim is that they would only have to pay ÂŁ2 million in tax, but in fact the money to pay that tax has to be extracted from the company, so the person who inherits it, rather than the company, pays it. Will the Minister confirm that? In other words, if the money was taken out in the form of dividends, it would be ÂŁ3.3 million, instead of ÂŁ2 million, and that would have a very real impact on a small company. In fact, it could be existential.
Dan Tomlinson
I will not get into specific worked examples. The general point is that the Government have made changes both to business property relief and to agricultural property relief, in order to raise additional revenue from the very wealthiest estates. We have sought to do that because we want to put fairness into our tax system.
The CBAM was mentioned by the Opposition, and by my hon. Friend the Member for Mid and South Pembrokeshire (Henry Tufnell). I thank him for his strong advocacy for his constituency, and the thousand people who work in the refinery there. The Government said at the Budget that we recognise the important role that refineries play in our energy security, and we are now considering the feasibility and impact of including refined products in the CBAM in future. It is very complicated, and there would be knock-on impacts on other sectors if the Government were to proceed with that. I have met representatives from the sector recently, and I will continue to engage with them.
Finally, I turn to new clause 4, which requires the Chancellor to report on how the regulations in the prohibition address the harm to individuals and businesses from online tax avoidance promotion, and the steps that His Majesty’s Revenue and Customs should take to inform the public of the risk posed by online tax avoidance. I thank my hon. Friend the Member for Walthamstow (Ms Creasy) for raising the important issue of avoidance promotion. I agree with her that it is appalling that these individuals promote tax avoidance schemes and get away with it. It causes misery to those caught up in the schemes, and deprives our public services of vital revenue. The Government are taking action via this Finance Bill to crack down on them.
I confirm to the House that the measures introduced in clauses 156 to 162 apply equally to those promoting avoidance schemes online, including on social media, and to those promoting them through more traditional routes. I can also confirm that the promoter action notice in clauses 163 to 173 will also apply.
I would also like to reassure my hon. Friend that we are publishing guidance on these matters, and I will ensure that it is clear throughout that the Government’s intention is to capture anyone who is promoting tax avoidance. This includes social media influencers who are making a monetary gain through clicks, as highlighted by my hon. Friend, and I would welcome her engagement in developing the guidance.
Ms Creasy
I thank all the MPs across the House—except those in the obvious party—who understand the risks to our constituents from this advice. It is very welcome to see a Government respond so quickly to social media problems, unlike the last one; we remember payday lending and the “buy now, pay later” lenders. The Minister talks about issuing guidance. Does he have a rough timeline for when that guidance will be available? I guess what I am really asking, on behalf of the millions of people who have been ripped off, is when Samuel Leeds will get a knock on the door from the taxman.
Dan Tomlinson
I look forward to working with my hon. Friend, and other Members who are interested in this topic, to make sure that we move as quickly as we possibly can. Let me thank all Members for their contributions during this this debate.
Question put and agreed to.
New clause 5 accordingly read a Second time, and added to the Bill.
New Clause 6
Offshore income gains: savings
“(1) This section applies in relation to an offshore income gain arising to the trustees of a settlement in a case where Chapter 2 of Part 13 of ITA 2007 (transfer of assets abroad) applies in relation to that gain for the tax year 2025-26 or any subsequent tax year because of the amendments made by section (Offshore income gains).
(2) If the offshore income gain arose in a tax year before the tax year 2025-26 and, by reason of that offshore income gain or a part of it, an offshore income gain was treated as arising in a tax year before the tax year 2025-26 to an individual under paragraphs (2) to (5) of regulation 20 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001)—
(a) Chapter 2 of Part 13 of ITA 2007 is to be treated as not applying in relation to the offshore income gain arising to the trustees or that part of that gain, and
(b) references in section 734 of ITA 2007 to chargeable gains treated as accruing to an individual are to be treated as including the offshore income gain treated as arising to the individual.
(3) An individual is not chargeable to income tax under Chapter 2 of Part 13 of ITA 2007 on income treated as arising to the individual under section 732 of ITA 2007 by reason of the offshore income gain to the extent that the income, without the amendments made by section (Offshore income gains)(1) and (2)(b)—
(a) would have been treated as arising to that individual under paragraphs (2) to (5) of regulation 20 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), and
(b) would have been non-chargeable income (see subsections (4), (5) and (6)).
(4) The income would have been non-chargeable income if, without the amendments made by section (Offshore income gains)(1) and (2)(b)—
(a) the income would have been treated as arising by reason of—
(i) the matching of a capital payment received (or treated as received) by the individual before 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or
(ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising before 6 April 2008, and
(b) paragraph 100 of Schedule 7 to FA 2008 would have applied to the income.
(5) The income would have been non-chargeable income to the extent that, without the amendments made by section (Offshore income gains)(1) and (2)(b), it would have exceeded the relevant proportion of income—
(a) which would have been treated as arising to the individual by reason of—
(i) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or
(ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising on or after 6 April 2008, and
(b) to which paragraph 101 of Schedule 7 to FA 2008 would have applied,
and, for that purpose, “relevant proportion” has the meaning given by sub-paragraphs (9) to (18) of paragraph 126 of that Schedule as they would have been modified by sub-paragraph (3) of paragraph 101 of that Schedule.
(6) The income would have been non-chargeable income to the extent that, without the amendments made by section (Offshore income gains)(1) and (2)(b), it would have exceeded the relevant proportion of income—
(a) which would have been treated as arising to the individual by reason of—
(i) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2008 with an offshore income gain arising on or after 6 April 2025, or
(ii) the matching of a capital payment received (or treated as received) by the individual on or after 6 April 2025 with an offshore income gain arising on or after 6 April 2008,
(b) to which paragraph 102 of Schedule 7 to FA 2008 would have applied, and
(c) to which paragraph 101 of that Schedule would not have applied,
and, for that purpose, “relevant proportion” has the meaning given by sub-paragraphs (4) to (7) of paragraph 127 of that Schedule as they would have been modified by sub-paragraph (4) of paragraph 102 of that Schedule.
(7) Subsection (3) does not prevent Chapter 2 of Part 13 of ITA 2007 from having effect as though the income not chargeable to tax under that subsection had been charged to tax under section 731 of that Act.
(8) Accordingly—
(a) in the application of section 733(1) of ITA 2007 to the individual for subsequent tax years, the amount of that income will be deducted at Step 2 and at paragraph (a) of Step 5, and
(b) in the application of section 733(1) of ITA 2007 to any other individual for subsequent tax years, the amount of that income will be deducted at paragraph (b) of Step 5.
(9) In section 733 of ITA 2007, after subsection (2D) insert—
“(2E) See subsections (7) and (8) of section (Offshore income gains: savings) of FA 2026 (offshore income gains: savings relating to amendments made by section (Offshore income gains) of that Act) for special provision about income that is treated as arising under section 732 but that is not chargeable to income tax under subsection (3) of that section.”
(10) This section—
(a) is to be treated as having come into force on 6 April 2025;
(b) has effect for the tax year 2025-26 and subsequent tax years.” —(Dan Tomlinson.)
Brought up, read the First and Second time, and added to the Bill.
New Clause 7
Pensions: abolition of the lifetime allowance charge
“(1) Paragraph 134 of Schedule 9 to FA 2024 (power to make further provision in connection with the abolition of the lifetime allowance charge) is amended as follows.
(2) In sub-paragraph (2)—
(a) for paragraph (b) substitute—
“(b) have effect for the tax years 2024-25 and 2025-26 (as well as subsequent tax years);”;
(b) in paragraph (d), at the end insert“(including any provision that could be made under paragraph 133)”.
(3) In sub-paragraph (3) omit “that increase any person’s liability to tax”.
(4) In sub-paragraph (4), for “5 April” substitute “30 June”.” —(Dan Tomlinson.)
Brought up, read the First and Second time, and added to the Bill.
New Clause 11
Uprating of allowance amounts for agricultural property
“The Chancellor of the Exchequer must, within six months of the passing of this Act, undertake and publish an assessment of the potential merits of uprating annually the relief allowance amount for agricultural property by the change in the value of agricultural land.”—(Charles Maynard.)
Brought up, and read the First time.
Question put, That the clause be read a Second time.
Finance (No. 2) Bill: Ways and Means (Amendment of Power to Make Further Provision Relating to Abolition of Lifetime Allowance Charge)
Dan Tomlinson ExcerptsWednesday 11th March 2026
(6Â months, 2Â weeks ago)
Commons ChamberRead Full debate Finance Act 2026 View all Finance Act 2026 Debates Read Hansard Text Watch Debate Read Debate Ministerial Extracts Amendment Paper: Report Stage Amendments as at 11 March 2026 - (11 Mar 2026)
The Exchequer Secretary to the Treasury (Dan Tomlinson)
I thank the hon. Member for Aberdeen North (Kirsty Blackman) for her remarks, as well as for her scrutiny of this process, which I appreciate no matter where it comes from.
The hon. Member is right to flag that this is not the typical process. For future Finance Bills, I will—if I am in my position—endeavour to ensure that Ways and Means motions are not brought at this late stage. She is also right to point out that this debate—although I do not believe that there are any other bobbers—and any debate on the subsequent motion could go on for 45 minutes, and that discussions may ensue. I would be happy to consider the process.
This technical amendment allows for the introduction of regulations required as part of the abolition of the lifetime allowance, in order to have a retrospective effect going back to the point when the lifetime allowance was originally abolished. That ensures that the changes we are making operate as intended. It is a small and technical measure, but I take the hon. Member’s point that it adds a new part to the Bill and means that a new resolution has been brought forward. I hope that—notwithstanding the valid points raised by the hon. Member—Members will understand that position, and I commend the motion to the House.
Question put and agreed to.
Finance (No.2) Bill: Ways and Means (Offshore income gains)
Motion made, and Question proposed (Standing Order No. 52(1)(b)),
That provision (including provision having effect for the tax year 2025-26) may be made revoking—
(a) paragraphs (2) to (5) of regulation 20 of the Offshore Funds (Tax) Regulations 2009, and
(b) paragraphs (4) to (6) of regulation 21 of those Regulations.—(Dan Tomlinson.)
Question agreed to.